Working Draft 

ISSUES MATRIX FOR THE SANTA SUSANA SEC PETITION 

AND NIOSH EVALUATION REPORT 

Contract Number 200-2009-28555

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

April 2009 

Updated September 2014 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
Santa Susana Issues Matrix 2 SC&A – September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of 

this matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

During the meeting of the Advisory Board on Radiation and Worker Health (the Board) held in 

Redondo Beach, California, on September 4, 2008, S. Cohen and Associates (SC&A) was 

directed by the Board to perform a “paper” review of the Santa Susana Field Laboratory (SSFL) 

Special Exposure Cohort (SEC) Petition-00093 and the National Institute for Occupational 

Safety and Health (NIOSH) SEC Petition Evaluation Report (ER) for said petition. 

Subsequently, during the meeting of the Board held in Augusta, Georgia, on December 18, 2008, 

SC&A was directed by the Board to perform the “full” review of the SSFL SEC Petitition-00093 

and the NIOSH SEC Petition ER. 

The NIOSH-proposed class includes all employees of the Department of Energy (DOE), its 

predecessor agencies, and DOE contractors and subcontractors who were monitored while 

working in any area of Area IV of the Santa Susana Field Laboratory for a number of work days 

aggregating at least 250 work days from January 1, 1955, through December 31, 1958, or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

The most recent SEC Petitions (the Mallinckrodt Chemical Company in St. Louis, Missouri; the 

Vitro Manufacturing facility in Canonsburg, Pennsylvania; and the Metallurgy Collaboratory in 

Chicago, Illinois) have included “all” employees present during a given time rather than the 

narrower class of those employees who were monitored. It is unclear why NIOSH has proposed 

a narrower addition to the SEC class in this case. 

This matrix contains an issues list for the Santa Susana SEC Petition. It is based on an 

assessment of the following: 

 The NIOSH ER dated February 6, 2008

 The Santa Susana SEC Petition SEC-00093

 SC&A’s Site Profile Review

 A review of relevant documents
Santa Susana Issues Matrix 3 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT 

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

1 The Sodium Reactor Experiment 

(SRE) Incident and Release of 

Core Gases. (Petitioner Issue) 

TBD-2 (ORAUT 2006a) contains a discussion of the 

SRE coolant failure in Section 2.2.1.1.2 and in Table 2-

6. Based on their review of claims in NIOSH OCAS 

Claims Tracking System (NOCTS), NIOSH concluded 

that personnel monitoring exists for members of the 

proposed class (both internal and external monitoring) 

during the timeframe of the SRE event. NIOSH also 

notes that some air monitoring measurements from the 

reactor area and stack monitoring exist. NIOSH states 

that several documents were reviewed in the 

preparation of the ER (Lochbaum 2006; Hart 1962),

beyond what was reviewed as part of the site profile. 

The potential that all staff may not have been adequately monitored combined 

with the seriousness of this event suggests that it may be necessary to develop 

an incident-specific exposure model or conclude that exposures cannot be 

properly evaluated.

Section 2.2.1.1.2 of TBD-2 provides very little information on the incident, and 

does not discuss any potential exposure information to workers. There is 

information in Table 2-6 about exposure being negligible for nearby residents (a 

maximum theoretical calculated dose of 0.06 rem to someone living in Susana 

Knolls), the nearest residential area at the time. There are at least two key 

documents (AI 1959 and 1961) that were prepared related to this incident that 

were not reviewed as part of the site profile or ER. 

NIOSH response: 

All technical reports and memos available though due diligence data capture 

were reviewed when evaluating the SRE incident (there are currently 82 

documents in the SRDB that are related to SRE operations and/or the incident in 

1959). The section of the SEC evaluation report addressing the petitioner 

concern was specifically related to reports detailing the release estimates, which 

are cited in the evaluation report. 

Specific technical reports can be found in the SRDB and include among others:

- Hart – Distribution of fission product contamination in the SRE, 1962, 

NAA-SR-6890

- SRE fuel element damage, final report, 1961, NAA-SR-4488 (suppl)

- SRE fuel damage interim report, 1959, NAA-SR-4488

NIOSH is currently proceeding with the development of internal and external 

coworker models, which can be applied to workers, who are thought to have 

been exposed during the incident and/or cleanup thereof. NIOSH is also 

pursuing an independent review of the different release estimates available, to 

determine the most scientifically defensible release scenario and therefore the

extent and the necessity of an exposure model for on-site workers. 

The revised TBD will contain additional detail of the incident and potential 

exposure implications.

2014 Update: None – issue closed on 4/20/2010 (pg. 47 of transcript)
Santa Susana Issues Matrix 4 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

2 Radiation Badges:

This issue was based on a Tiger 

Team report indicating 

“inadequate radiation badges.”

(Petitioner Issue)

NIOSH’s response to this issue is captured in the 

following statement: 

The Tiger Team Report cited by the petitioner 

does not state that dosimeters were inadequate, 

but that they were not Department of Energy 

Laboratory Accreditation Program (DOELAP) 

accredited, and it specifically focuses on the 

D&D period versus the period being evaluated 

in this report. As it relates to the program 

being discussed in the Tiger Team Report, it 

was common practice (and is noted as an 

option in Section 7 of the DOELAP 

Administrative Standard DOE-STD-1111-98) 

for smaller programs to be exempted from 

DOELAP accreditation, contingent upon using 

a National Voluntary Laboratory Accreditation

Program (NVLAP)-accredited commercial 

service [DOE 1998]. However, this is pertinent 

only beginning in 1986 when the DOELAP 

requirements were implemented. Therefore, as 

discussed previously, the period cited in the 

petition is after the period of the evaluation and 

does not impact the ER.

SC&A concurs with NIOSH’s response, assuming the petitioner was not 

referring to some other concern than the adequacy of the badges. 

NIOSH response: 

no response needed

2014 Update: None. Issue closed.

3 Tritium Plumes: 

Workers may have been exposed 

to drinking water contaminated 

with tritium.

(Petitioner Issue)

NIOSH states that tritium has never been detected 

(>1,000 pCi/l) in any of the water supply wells. 

NIOSH also asserts that the primary supply wells (WS5, WS-6, WS-12, and WS-13) were in Areas I, II, and 

III; one well (WS-7) was in Area IV and contributed a 

small percentage of the water supply. NIOSH has 

proposed to bound this exposure by assuming that 

workers consumed water from a shallow monitoring 

well with the highest tritium concentration. NIOSH 

maintains that this well has never been used for potable

water and is downgradient of the tritium source 

(Building 4010). According to the NIOSH ER, the 

The assumptions seem to be claimant favorable, except for the fact that more 

recent Boeing reports (Boeing 2003, 2004, 2005, and 2006) have documented 

tritium concentrations in the monitoring wells reaching 117,000 pCi/l. Potential 

tritium concentrations in the wells should be reassessed, given this information.

NIOSH response (please note that this is the information initially to be 

presented in a NIOSH White paper, however, NIOSH felt that this matter could 

be dealt with more efficiently by instead including the information in its 

entirety in the issues matrix):

NIOSH did not claim that the sampling well (RD-34A) used as a basis for the 

bounding calculations was the one with the highest concentration ever found. 
Santa Susana Issues Matrix 5 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

mean concentration of tritium in WS-7 has been 2,940 

pCi/l since 1991. Through some modeling of migration 

and decay assumptions, NIOSH concluded that workers 

could have consumed water with 30,000 pCi/l of 

tritium in the 1950s and 1960s. 

Well RD-34A was selected because it is downgradient of Building 4010 (the 

source of the tritium) and because tritium has been constantly detected there 

since 1991. NIOSH did not intend to use the highest concentration found on 

site. 

The information in the cited environmental reports was included in NIOSH’s 

evaluation of the mean concentration in well RD-34A. A reference to 117,000 

pCi/L is found in the Site Environmental Report for Calendar Year 2006, which 

also states that this highest level was found in well RD-95 in 2005. This well is 

to the west of and closer to the assumed source in Building 4010. The only 

drinking water source in Area IV, WS-07, is east-northeast of this building. 

Sampling well RD-34A is in the general direction of this well. 

Since this assessment, Site Environmental Report for Calendar Year 2007 has 

been issued. Data for sampling wells that are in the general direction of WS-07 

were reviewed (RD-17, RD-27, RD-30, RD-63, RD-85, RD-86). Other than 

RD-34A, there was only one other well with a positive result, RD-63 at 350 

pCi/L on 02/16/06. Two samples taken in 2007 were below the detection level 

for this well. 

Based on this information, NIOSH concludes that the choice of well RD-34A 

provides the best data for a bounding estimate.

See the following references for more detail including maps of the area and 

location of the plume and the former drinking water wells:

 The Boeing Company, 2008, Site Environmental Report for Calendar Year 2007, 

DOE Operations at The Boeing Company, Santa Susana Field Laboratory, Area IV, 

September

 Haley & Aldrich, 2007, Analysis of Potential for Tritium in Water Supply at SSFL, 

PowerPoint slide presentation, undated, SRDB 41888

2014 Update: Closed

A revision to the environmental TBD includes potential intakes of tritium by 

workers. The document is awaiting approval pending final approval of the external 

coworker model. Issue was closed on 4/20/2010 (pg. 56 of transcript).
Santa Susana Issues Matrix 6 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

4 Uranium Fires: 

The petitioner refers to

numerous uranium fires, cites 

two incidents of a sodium 

explosion, and expresses

concern that monitoring was 

lacking regarding facility 

incidents. (Petitioner Issue)

NIOSH has concluded that there are data available for 

the various uranium fires that would allow dose 

estimates to be bounded.

SC&A reviewed over 40 Radiological Safety Incident Reports specific to 

uranium fires. These reports include information on uranium quantities, 

mixtures and enrichment levels, causal factors contributing to the fires, air and 

surface sampling data prior to decontamination, and details on personnel 

involved, including monitoring procedures (e.g. bioassay, nasal smears) and 

whether personnel were exposed or wearing protective gear. 

Therefore, SC&A is in agreement with the conclusions of NIOSH that bounding 

dose estimates are possible regarding uranium fire incidents (Alexander 1967a,

b, c, and d; Badger 1960 and 1961; Begley 1976; Harrison 1986; Klostermann 

1961; Loba 1959, 1960, 1961a, 1961b, 1962 and 1970; Oldfield 1961; Mooers 

1959a and 1959b, 1960 and 1961 a, b, and c; Owens 1978; Rudkin 1964a, b and 

c; Stephenson 1961, 1962, 1963a and 1963b; Weber 1963; Young 1960 and 

1965).

Lack of monitoring for workers involved in facility incidents is discussed 

further in this document (see SRE, Issue #1; Sodium Disposal Facility, Issue #6;

and SC&A Issue #3).

NIOSH response:

No NIOSH response needed, some of this issue addressed later

2014 Update – Closed

5 Air Monitoring:

The petitioner maintains that air 

monitoring was insufficient. 

(Petitioner Issue)

NIOSH has concurred that there is a lack of air 

monitoring for the period at SSFL-Area IV prior to 

1958, which impacts the feasibility of accurately 

estimating internal radiation doses for the proposed 

worker class during that time period. After 1958, dose 

reconstructions were primarily based on bioassay data.

TBD-4 (ORAUT 2007) provides guidance for 

assigning occupational environmental doses for Area 

IV, Downey, Canoga, and De Soto sites of SSFL from 

1954 to 1999. 

Sections 4.6.4, 4.6.5, and 4.6.6 of TBD-4 acknowledge 

the lack of external dose rate monitoring data prior to 

1974, and provide unsubstantiated assumptions that 

SC&A concurs with conclusions made by NIOSH regarding insufficient air 

monitoring prior to 1958.

SC&A questions the post-1958 data and/unsubstantiated assumptions that were 

applied in order to reconstruct occupational environmental doses, due to 

insufficient environmental monitoring and data limitations. 

In addition, monitoring for internal exposure of SSFL workers was incomplete 

and poorly documented for most years of facility operation. These deficiencies 

and data limitations are stated throughout sections of the TBD. SC&A does not 

believe that NIOSH has clearly demonstrated a correlation between the bioassay 

data and the potential exposures to specific radionuclides after 1958.

NIOSH response: 

Please see response 4.5-1 from TBD issues matrix. In general internal 

monitoring is documented starting in 1958, but the number of people monitored 
Santa Susana Issues Matrix 7 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

were used to derive annual external dose estimates for a 

restricted number of facilities. 

Environmental inhalation intakes were calculated using

facility stack emission data, and included annual gross 

alpha/beta concentrations at the stack point of release. 

This data was adjusted by a reduction factor of 0.01 to 

account for decreased intake due to contribution from 

multiple, widely spaced facilities; atmospheric 

dispersion of stack effluent and building wake effects. 

Stack emission data varied by facility, but covered 

most years between 1971 and 1999. In addition, stack 

emission data were used to characterize radionuclides 

for the period 1988–1999 and extrapolated to cover all 

years. 

is small at first, but is steadily increasing until 1962, which seems in accordance 

with the scope of operations at the site. NIOSH found no evidence that internal 

monitoring data was incomplete or poorly documented, but the data from the

earlier years is more limited. This issue will be further evaluated in the

determination of the feasibility of the internal coworker model.

Furthermore, SC&A asserts that stack emissions data are not an adequate 

method to assess onsite worker exposures in areas with buildings or in facilities 

that include outdoor operations with contaminated materials, such as the Burn 

Pit.

NIOSH response: 

NIOSH is currently in the process of reviewing the ambient intake approach and 

is also pursuing the development of a coworker model for internal and external 

exposures, which rely on external film badge/TLD data and internal bioassay 

data.

2014 Update: Open.

Additional information obtained from new reference materials was added 

to the environmental TBD. The added stack release information and 

external environmental monitoring information significantly modified the 

previous guidance on ambient external dose and inhalation intakes. 

An analysis was added addressing the potential intake of tritium in 

groundwater by workers.

An internal coworker model based on internal monitoring has been 

completed for the entire non-SEC operations period. 

6 The Sodium Disposal Facility 

(also known as the Sodium Burn 

Pit): This facility was not 

adequately monitored and/or 

records are missing. (Petitioner 

Issue)

NIOSH concludes that while there may have been 

radiological contamination at the Sodium Burn Pit, the 

following details are presented suggesting low 

exposures and the ability to bound dose estimates:

 Radiological contaminant levels were estimated 

to be no greater than 56 pCi/g; radionuclides of 

concern were cesium-137, thorium, and 

strontium. Cs-137 was also found in the lower 

collecting pond. 

Contamination was identified in the Sodium Burn Pit in 1978, at which time 

monitoring of the area began and continued until 1983. Prior to 1978, no 

radioactivity was expected in this area, thus raising questions whether 

individuals involved in these activities would have been considered for internal 

monitoring. The Sodium Burn Pit was not expected to result in radiation 

exposures and was not routinely monitored. Additional information should be 

gathered on this site to demonstrate that unmonitored workers are not likely to 

have received sufficient dose to be of concern, or a model should be developed 

to ascertain the exposures that could have been incurred.
Santa Susana Issues Matrix 8 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

 The Sodium Burn Pit was located in open air 

discontinuously occupied and not considered to 

be an operations area.

 In the ER, NIOSH asserts that radiological 

exposures were unlikely; due to the explosive 

nature of the reactions taking place, safety 

precautions regarding chemical exposures were 

instituted at this facility from its inception.

 After radiological contamination was discovered, 

radiation surveys and soil samples were 

conducted from 1978 through 1983. 

 Actual bioassay results and associated monitoring 

program data were available and included worstcase scenarios for the proposed worker class. 

Worker exposures may have included a complex mixture of highly enriched 

uranium, actinides, MFPs, and various activation products, including large 

amounts of Na-24.

NIOSH response (please note that this is the information initially to be 

presented in a NIOSH White paper, however, NIOSH felt that this matter could 

be dealt with more efficiently by instead including the information in its 

entirety in the issues matrix):

Since the presentation of the Evaluation Report to the Advisory Board, NIOSH 

has been pursuing the bioassay data needed for an internal dose coworker study. 

The data were collected and analyzed by an independent contractor to produce 

an epidemiology study. The main obstacle to obtaining the data has been the 

concern over protecting the worker’s privacy right. Assuming that NIOSH will 

be successful in obtaining these data, it would be used to assign doses to 

workers at the burn pit who may have been unmonitored. NIOSH believes that 

this would be favorable to claimants for the following reasons:

 The area was open and unconfined, so airborne concentrations would 

have been lower than in fixed facilities.

 Potentially violent reactions were known about and expected. 

Explosive safety would have prevented close contact with the 

hazardous materials during such reactions, regardless of whether the 

workers suspected radioactive contamination or not.

 Exposures were intermittent.

 The radioactive contamination found at the burn pit is known from soil 

samples to consist of low levels of fission products, principally Cs-137. 

NIOSH has published a method in ORAUT-OTIB-0054 to determine 

the mixture of radionuclides present given a gross urinalysis (such as 

in the example cited by SC&A).

The sodium burn pit operations were non-routine activities, since it was only 

used for intermittent sodium disposal. From claimant data, it appears that 

personnel at the burn pit often consisted of firemen, who tended to be included 

in the radiation worker group, based on interviews with an HP expert and a 

fireman.
Santa Susana Issues Matrix 9 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

Regarding the SC&A concern about the validity of environmental data

expressed in the ER review: Environmental soil concentration data are not used 

for dose reconstructions at SSFL since internal and external dosimetry data are 

available. The issues with the EPA and the methods used for environmental data 

are not directly applicable here. 

TBD-5 does not address internal exposures to unmonitored workers, since that 

is discussed in TBD-4 (environmental TBD).

Na-24 is produced by neutron activation in the primary coolant loop of the 

sodium reactor, and was a known (short lived, 15 hr half life) external radiation 

hazard. The sodium burn pit was inadvertently contaminated with fission 

products but the radioactivity levels found there do not lead to the conclusion 

that it was used to routinely dispose of large amounts of primary loop sodium. 

The chemical hazard posed by Na reacting with water would require safety 

measures to prevent inhalation of Na vapor, which is a chemical hazard.

2014 Update: Open. 

Internal coworker model was completed; external coworker model was 

completely revised and is in approval stages. Those models can be used to 

assign any unmonitored dose from SSFL facility operations.

7 Other Issue #1: 

Identification of workers with 

blank radiation exposure record 

sheets in their file. (Petitioner 

Issue)

NIOSH comment: actually not 

a petitioner issue, but a 

NIOSH identified issue

NIOSH discovered through an interview with a current 

Radiation Safety Officer at SSFL that all individuals 

were issued a blank record sheet in his/her file called a 

“blue card.” If an individual entered into a “controlled” 

area, they were required to have a film badge and any 

exposure was entered into their file. This practice was 

corroborated by NIOSH through random personnel 

record reviews and other reviews (Boice et al. 2006a 

and Boice et al. 2006b).

SC&A acknowledges this practice, based on a review of two studies conducted 

by Boice et al. (2006a, 2006b) and site interviews. The reports substantiate the 

use of ‘blue cards,’ also known as Kardex cards, that were used to identify 

Rocketdyne (AI) employees. These cards included employee name, Social 

Security numbers, employee serial numbers, hiring date, birthdate, complete job 

history (e.g., occupational title, occupational code, pay type, department, and 

dates of job change or termination). While it is recognized that individuals were 

required to have a film badge upon entering a controlled area, there is 

insufficient information available in the cited reports to conclude this occurred 

all the time.

SC&A interviewed several former employees about their work at SSFL. Some 

of the workers do not recall being issued a badge when they were working in or 

passing through a radiological area. 
Santa Susana Issues Matrix 10 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

NIOSH response: 

Generally a radiation badge was issued for a worker routinely working in an 

area with an exposure potential. Workers passing through a controlled area 

would not necessarily be considered as such, but based on claimant data, visitor 

badges were issued to some non-routine workers in a controlled area. 

NIOSH has completed the external coworker model, which will be used to 

assign doses for workers who are determined to fall into this category. 

2014 Update: Open.

Revised external coworker model is in the completion stages. This can be 

used to assign unmonitored dose to workers. 

8 Other Issue #2:

Monitoring of firemen from 

other sites who were involved 

with fires or other events at 

SSFL. (Petitioner Issue)

NIOSH comment: actually not 

a petitioner issue, but a 

NIOSH identified issue

NIOSH asserts that firemen wore film badges when 

working in areas with the potential for radiological 

exposures. One person interviewed mentioned that 

firemen consistently wore badges; however, one 

fireman did not have monitoring records in his file. 

The SEC petition ER concludes the following:

As previously discussed and stated, the 

availability of personnel records for monitored 

individuals supports NIOSH’s ability to 

reconstruct dose with sufficient accuracy for 

those proposed worker class members. 

Because the available data also includes a 

representation of the maximum potential 

exposures (a bounding exposure scenario) for 

the proposed worker class, NIOSH contends 

that this supports the ability to bound the 

associated dose for all members of the 

proposed worker class, including dose 

associated with the exposure scenarios 

presented by/for these firemen.

SC&A questions the adequacy and availability of monitoring records for 

firemen, particularly in reference to facility incidents, such as fires in the 

Sodium Burn Pit. Since little or no monitoring existed for these incidents, 

SC&A questions the process for concluding that the existing records are 

bounding and applicable to reconstructing actual source terms. 

NIOSH response: 

Fires in the sodium burn pit were not considered incidents per se, since they 

were planned activities occurring on an as-need basis. See response to the 

sodium burn pit issue (No 6). 

2014 Update: Open.

No additional information to add. Coworker models can be used to assign 

any unmonitored dose. Incidents can be assessed on an individual basis.
Santa Susana Issues Matrix 11 SC&A –September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of this 

matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

SANTA SUSANA SEC ISSUES MATRIX – DRAFT PRELIMINARY SC&A ASSESSMENT

No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

9 SC&A Issue #1:

Which areas (Area IV, Canoga 

Park, De Soto, and Downey) 

should be considered in the SEC 

petition and when did operations 

begin at these facilities

(coverage dates)?

There are three other operations addressed in the site 

profile—the Canoga Park, De Soto, and Downey

locations. NIOSH considers these facilities as 

individual covered areas and does not include them in 

the SEC Petition-00093. The dates of operation of all 

the facilities are not consistent within the Site Profile 

documents or the ER.

Facilities and their initial coverage dates need to be defined more clearly for 

SSFL. A review of SEC Petition-00093 and relevant support documents 

elucidated referential discrepancies:

 The list of covered sites in the DOE database is not consistent with the 

list of covered sites identified in the August 23, 2004, Federal Register.

 The TBDs focus on Area IV of the Santa Susana Field Laboratory, but 

also address the Canoga, Downey, and De Soto facilities. Dose 

reconstructions that are prepared for employees of AI include work 

conducted at all four of these facilities. The AI Division of NAA 

operated all four of these facilities, and their internal and external dose 

monitoring programs were the same for all the facilities.

 If coverage is limited to Area IV, the initial date of coverage is presented 

in the TBDs as 1953, 1954, or 1955. The initial date of coverage for 

Area IV is shown as 1955 in 42 CFR Part 83.9 and the DOE “covered 

facilities” database. If it is determined that all four facilities will be 

included in the SEC Petition, the initial coverage date will need to be 

changed to 1947 or 1948. 

Given the above, we believe NIOSH should re-assess the SEC Petition as

applicable only to Area IV at SSFL and define coverage dates as necessary.

NIOSH response: 

Per SEC rule 83.13 a petition is submitted by a petitioner who indicates on his 

petition for which class of workers and which site he/she is petitioning for. The 

petitioner’s intent is clarified in a consult call and follow up letter. Per 42 CFR 

Part 83.9(c)(1)(i) a single petition can only represent a single site, but a 

petitioner is free to submit a petition for any site where he/she has verified 

employment. This was discussed with the petitioner during the consult call 

(OSA 103548) and it was the petitioner’s intent to submit a petition for a class 

of workers who worked in all area of Area IV of the Santa Susana Field 

Laboratory, which is the class that was evaluated by NIOSH as outlined in the 

SEC ER 

The evaluation report covers Area IV of the Santa Susana Field Laboratory, 

with coverage start date in 1955 as outlined in class definition on the first page. 

Coverage dates are not determined by NIOSH, and some preliminary research 

into facility operation start date at Area IV SSFL, did not indicate that 

radiological operations started before that date

Regarding coverage dates: 

Figure 4.5.3-1 (originally from Sapere and Boeing, 2005*) shows that only 2 

facilities were in use pre-1955: the SRE and the KEWB facilityboth listed 
Santa Susana Issues Matrix 12 SC&A –September 2014 

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No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

10 SC&A Issue #2

Adequacy of the internal 

monitoring program, pre-and 

post-January 1, 1959.

Main Concerns:

(1) Incomplete bioassay 

dataset and insufficient 

correlation of bioassay data 

to specific radionuclides 

(2) Missing radionuclides

(3) Difficulties with uranium 

bioassay methods

(4) No internal coworker 

model or source term data

(5) Erroneous data 

interpretation 

(1) NIOSH identified limited amounts of internal 

personnel monitoring data for pre-1959 

exposures, which is consistent with its finding 

that an SSFL routine bioassay program was not 

initiated until August 1958 (Kellehar 1966). Two 

sources (NIOSH 2008, ORAUT 2006c) state that 

there is sufficient bioassay and other supporting 

data available after 1959 to establish an upper 

bound for uranium, mixed fission products 

(MFPs), Po-210, plutonium, SR-90, tritium, and 

thorium. 

(2) NIOSH maintains that bioassay data were 

available for gross alpha, gross beta, uranium, 

fission products, plutonium, thorium, Po-210, Sr90, H-3, P-32, S-35, C-14, Pm-147, americium, 

and curium. Fission products were monitored for 

49% of the workers. (not sure where this comes 

from)

(3) Uranium at SSFL to which workers may have 

been exposed existed in various degrees of 

enrichment (i.e., 2% to 93%). Section 5.3 of 

TBD-5 (ORAUT 2006b) discusses the two 

independent methods used to assess uranium in 

urine; the fluorometric method identifies uranium 

concentrations, while the radiometric method 

assesses the gross alpha/beta energies.

(4) TBD-5 states the following:

Without bioassay or air sample 

data, the last resort is determination 

of airborne concentrations using 

source term evaluations (NIOSH 

2002, p. 19). Data on the amount of 

dispersible material available does 

not appear to be available for 

(1) For the period post-1959, SC&A does not believe that these sources 

(NIOSH 2008, ORAUT 2006c) have clearly demonstrated a correlation 

between the available bioassay data to specific radionuclides. A brief 

review of claimant files illustrates that monitoring was not routine for all 

radiation workers. Detection limits for 1975–1988 are unavailable, and 

Table 5-9 in TBD-5 containing solubility type and fraction of activity is 

incomplete. Furthermore, though the number of bioassays increased 

significantly in the 1965 to 1970 timeframe, there were still deficiencies 

with respect to the full range of different radionuclides to which workers 

were exposed. 

NIOSH response: Over the course of operations, on average 47 % of radiation 

workers were monitored internally, but not all of them on a routine basis. A 

revision of the TBD will include a discussion on the exposure potential and 

the available data. 

(2) Of the 37 internal monitoring records available to SC&A, the vast 

majority of monitoring was for uranium and mixed fission products; 78% 

and 62%, respectively. Only a few monitoring records exist for the 

following radionuclides: 8% for cesium, 3% for beryllium, 3% for 

mercury, 3% for potassium, 0% for polonium, 24% for plutonium, 5% for 

strontium, 14% for tritium, and 0% for thorium. Potential exposure to 

radionuclides such as U-233 and U-234 could have occurred during these 

operations, but cannot be confirmed due to uranium monitoring

limitations.

NIOSH response: Uranium bioassay was conducted from the start of the 

routine program. U-233 was present as fuel in the Advanced Epithermal 

Thorium Reactor (AETR) which, in spite of its name, was a critical test 

assembly unlikely to result in internal exposures of U-233.

(3) The TBD does not clarify whether urine samples prior to 1961 were 

analyzed by both Uranium Fluorometric (UF) and Uranium Radiometric

(UR) methods. Beginning in 1962, the type of urinalysis methods used 

was usually specified.

NIOSH response: the capacity for both analyses methods was present since 

the start up of the bioassay program, although the majority of the 1958-1961
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No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

ETEC.

(5) TBD-5 has several occasions where data 

interpretation is not complete.

results available in claimant files were for radiometric uranium.

The assumption presented in the report that the early uranium urinalyses were 

limited to fluorometric analyses is not valid, as supported by documentation 

such as SRDB Ref ID 39919, which describes the uranium electrodepositing 

and counting method and also lists some early U and GB results from 1958; 

SRDB Ref ID 1959 also shows that radiometric and fluorometric analysis 

capability were planned.

(4) NIOSH asserts that an internal coworker model is unnecessary, and does 

not address the use of a coworker model for unmonitored individuals. In 

many cases, the dose reconstruction reports rely on guidance developed 

for internal dosimetry based non-SSFL site data that may not accurately 

reflect conditions at SSFL. NIOSH should make use of the data that 

Boeing appears to have to see if they are sufficient to estimate dose. 

There is no way to tell whether the doses in the Boeing spreadsheet 

would qualify as bounding doses (or more accurate than that) under 

42 CFR 83. Due to the magnitude of such an investigation, SC&A did 

not perform such an assessment, but we believe that NIOSH will need to 

perform this assessment in order to support the conclusions and 

recommendations in the ER.

NIOSH response: NIOSH has been pursuing the development of an internal 

coworker model, using the computerized data bases containing complete 

bioassay monitoring results are available from the earlier epidemiological study 

by Boice et al. (2006). This effort is on-going and has been hampered by site 

funding issues. 

(5) See our review of TBD-5 for specific comments on data interpretation 

issues.

NIOSH response: please see TBD issues matrix responses for TBD-5

2014 Update: Open

The internal coworker model was completed after the personnel dosimetry 

database was received from Boeing. NIOSH has dismissed database

related to the Boice study and completed its own data entry effort, which 
Santa Susana Issues Matrix 14 SC&A –September 2014 

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No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

ensures that no data were missed. Data were analyzed and are presented in 

the internal coworker model OTIB-0080.

11 SC&A Issue #3:

Lack of information related to 

the potential exposures 

associated with facility 

“incidents” (e.g. Sodium Reactor 

Experiment and Sodium Burn 

Pit).

The NIOSH ER does not include substantive details 

regarding potential SSFL personnel exposures resulting 

from facility incidents. 

Atomics International prepared two reports on the SRE incident; a report titled 

SRE Fuel Element Damage, An Interim Report (NAA-SR-4488)—November 15, 

1959 (AI 1959), and a second report titled, SRE Fuel Element Damage, Final 

Report (NAA-SR-4488 (suppl)—1961 (AI 1961). The interim report (AI 1959) 

contains important information related to this incident that is not in the site 

profile:

 During this occasion, specifically, in October 1958, the maximum 

radiation levels in the general area of the moderator coolant pump were 

reported to be about 50 mr/hr (October 14). Below shield blocks 1 and 

2, the radiation level was about 21 mr/hr (on October 11). (p. IV-C-9)

 Radiation levels measured on April 18, 1959 varied from 50 to 420 

mr/hr. ...Additional measurements made 5 days later (a total of 17 days 

after shutdown) indicated no significant decay. (p. IV-C-10) [Table IVC-6 includes radiation levels in the Gamma Facility on various dates in 

August, September, and October of 1959. The measured radiation 

levels peaked on August 12 (2.9 r/hr) and decreased to 0.7 r/hr on 

October 5.] 

 Cold trapping was started during run 14. However, radiation 

measurements could not start until August 8 (due to the radiation 

hazard from the high radiation levels of Na24), at which time the dose 

rate, extrapolated to near the surface, was about 70 r/hr. It is possible 

that initial cold-trap dose rates, had they been measured, would have 

yielded significantly higher values. (p. IV-C-12) [The radiation rates at 

the cold trap, shown in Table IV-C-7, range from 63 r/hr on August 8, 

1959, to 50 r/hr, with a peak of 81 r/hr on August 13.] 

 Following the termination of run 14, the fuel handling cask was used to 

inspect the fuel elements in the reactor. ... Operations directed towards 

removal of these slugs resulted in occasional radiation levels as high as 

1000 r/hr at 1 ft. from the slugs. However, the maximum total exposure 

received by operations personnel during these cask operations did not 

exceed 1 rem in a single week. (p. IV-C-22) [The basis for this last 
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No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

statement was not provided in the report, and the number of personnel 

exposed was also not presented.] 

The final report (AI 1961) contains information related to potential worker 

exposure. Examples include the following:

 This report discusses the distribution and management of the fission 

products during the recovery operations. During the recovery effort the 

objectives were: (1) To limit personnel exposure to an average dosage 

rate of 1.25 rem/quarter (5 rem/yr). (p. III-19)

 Throughout the recovery effort the radiation exposure to each 

individual was limited to less than 5 rem/yr. It was occasionally 

necessary to permit the weekly exposure for some key individuals to 

reach 600 mrem per week, in which case the individual was not exposed 

to radiation during the following week. Such exposures required a 

special permit, and only 30 permits were issued. For the 150 persons 

directly involved in the work, the average exposure was 2 rem/yr.

This information is pertinent to reconstructing both external and internal 

exposures associated with this incident.

NIOSH response: 

NIOSH has used information from these reports for dose reconstruction when it 

was relevant for a given claim. Additional guidance will be added to the revised 

TBD. Not all incidents are typically discussed in a TBD, even though the SRE 

incident should be addressed – see earlier response to this issue

The TBD also does not consider exposure to contaminated soil that has resulted 

from spills and other incidental releases. For example, a review by a U.S. 

Environmental Protection Agency (EPA) official in 1989 (Dempsey 1989) 

identified Building 064, the Special Nuclear Materials Storage Area, that had 

been contaminated as a result of a spill. This EPA official also had concerns 

about the validity of some, if not all, of their environmental data:

In the Rocketdyne procedure, soils are heated in a muffle furnace for 8 

hours at 500oC. Several problems were identified: first, this 

temperature is sufficient to volatilize most man-made radionuclides of 

concern, including cesium-137 and strontium-90. Second, from the 
Santa Susana Issues Matrix 16 SC&A –September 2014 

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No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

Rocketdyne procedure, soil is sieved through a coors crucible to obtain 

uniform particle size.... This procedure is a screening method at best 

and is not an accurate quantitative procedure.

SC&A concludes that there is a lack of information concerning facility incidents

that had significant potential for internal and/or external exposure to personnel.

NIOSH response: 

NIOSH does not use source term or environmental data for DR approaches for 

this site, since personal internal and external monitoring data are available. 

Coworker doses can be assigned if a worker was not monitored but should have 

been. 

2014 Update: Open.

Coworker models have been completed and can be used to assign doses to 

unmonitored workers who should have been monitored for exposures.

Incident information is assessed on an individual claim basis and 

information such as presented in the SRE incident reports are 

incorporated in individual dose reconstructions if needed for claim 

completion.

12 SC&A Issue #4:

Lack of information on 

environmental exposures.

(1) TBD-4 (ORAUT 2007) provides guidance and 

data for assigning occupational environmental 

doses for Area IV, and the Downey, Canoga, and 

De Soto sites that make up SSFL, for all years, 

starting with 1954 through 1999. Sections 4.6.4, 

4.6.5, and 4.6.6 of TBD-4 acknowledge the lack 

of external dose rate monitoring data prior to 

1974, and provide unsupported/unreferenced 

assumptions that were used to derive annual 

external dose estimates for a restricted number of 

facilities, as given in Table 4-4 of the TBD.

(2) The SEC ER states that onsite water supply wells 

were the primary water source from 1949 to 1964, 

which differs from Section 4.7 of TBD-4, which 

states, “Potable water is not a source of 

occupational radioactive material at SSFL, 

(1) The surrogate use of the time-integrated average yearly gross alpha/gross 

beta stack emissions corresponding to years 1971 to 1999 (when stack 

measurements were taken) is likely to underestimate stack emissions for 

years 1954 through 1970. SC&A’s conclusion is supported by the steady 

reduction in facility operations over time. For example, nuclear reactor 

programs were essentially phased out in the early 1970s.

NIOSH response:

TBD-4 is currently undergoing review to include additional information that 

was collected during the SEC research. The approach regarding stack data backextrapolation will be reviewed for the revision of TBD-4.

(2) Although the ER stated that the drinking water supply wells did not have 

elevated levels of tritium (>1,000 pCi/l) (concern with tritium given 

current tritium plume on site), the ER has tried to bound any 

contamination that may have existed onsite by assuming the onsite supply 

wells were contaminated with tritium at a concentration of 30,000 pCi/l. 
Santa Susana Issues Matrix 17 SC&A –September 2014 

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No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

because the SSFL facilities used either bottled 

water from an off-site vendor (Moore et al. 1962) 

or the city water supply.” In addition, other 

references (Winzer 1980 and 1981; Curphey 

1983) indicate that well water was a source of 

drinking water into the 1980s. 

More recent Boeing reports (Boeing 2003, 2004, 2005, and 2006) have 

documented tritium concentrations approaching 117,000 pCi/L in the 

monitoring wells. This issue should be re-evaluated to determine if this 

exposure route can be assessed.

NIOSH response: 

see tritium in groundwater issue (No. 3)

2014 Update: Open.

The environmental TBD was revised to include updated information. The 

TBD is in draft status pending issue resolution related to the external 

coworker model.

13 SC&A Issue #5: Justification for 

assignment of external dose 

estimates is not provided, and 

there is no coworker model for 

external exposures (personnel 

records are also of concern).

Main concerns:

(1) No external coworker 

model

(2) Workers were unlikely to 

have been monitored for 

thermal neutrons

(3) Dosimeter response to lowenergy photons

NIOSH maintains in the ER that information on 

ambient environmental external dose is unavailable for 

1955 through 1965, but did exist for the mid-1970s and 

forward. Baseline doses above background for Area IV 

were estimated using the available data, and are given 

as 20 mrem/year for 1955–1965. For the RMDF, a 

facility-specific dose was estimated to be 80 

mrem/year, and during SRE operations, a facility dose 

of 40 mrem/year was applied to Building 4143. 

NIOSH concludes that “the ambient environmental 

method does not support a bounding external exposure 

evaluation method for the timeframe evaluated [in the 

ER], in support of radiological dose reconstructions for 

the proposed worker class. However, the available 

ambient environmental data can be used to bound the 

external ambient doses for unmonitored workers during 

the evaluation period.”

TBD-6 (2006c) contains documentation to assist in the 

evaluation of occupational external doses from 

processes that occurred at SSFL. An objective of this 

document is to provide supporting technical data using 

(1) It appears that individuals may have been unknowingly exposed to 

radiation. An October 22, 1962, memorandum from F.H. Badger1to the 

Health and Safety File regarding “Health and Safety Observations at 

RMDF” states that, “Routine smear surveys have repeatedly revealed 

significant contamination or radiation dose rates in areas usually thought 

to be free of radioactive material.” One of the examples provided was a 4 

rad/hr capsule lying in an area thought to be uncontaminated.

In addition, an April 1991 Tiger Team Assessment (DOE 1991), 

questioned the external radiation dosimetry program, stating,“In 1989 and 

1990, extremity doses were not added in to exposure records or reported 

to the Radiation Exposure Information Reporting System (REIRS).”

In general, monitoring of SSFL employees appeared to be somewhat

indiscriminate; radiation workers may or may not have worn badges, and 

non-radiation workers could conceivably have incurred external

exposures. Identification of job titles may yield potential exposure 

information upon which a dose reconstruction is based and subsequently

linked to a coworker model. This issue is relevant to the SEC petition 

limitation of employees who “were monitored.” SC&A concludes that 

NIOSH must re-assess the SEC petition limitation.

NIOSH response:

 

1

 F.H. Badger was employed by Atomics International. His title was Analyst, Health Physics, Senior Health and Safety Operations.
Santa Susana Issues Matrix 18 SC&A –September 2014 

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No. Issue SC&A’s Understanding of the NIOSH ER Position SC&A Initial Review/NIOSH RESPONSE

claimant-favorable assumptions to evaluate 

occupational external doses that can be reasonably 

associated with worker radiation exposures. This 

document addresses the evaluation of unmonitored and 

monitored worker exposure, missed dose, and the bias 

and uncertainty associated with the monitoring of 

external dose.

(1) The ER affirms: “Further research and 

development of a co-worker data set has not been 

performed by NIOSH because a dosimetry data 

deficiency has not been identified for the 

proposed worker class timeframe. In the case that 

a co-worker study is deemed necessary, NIOSH 

believes that sufficient data exist to support a coworker study and dose reconstruction approach.”

(2) As stated in Section 6.2 of TBD-6, “...Both fast 

and thermal neutrons were measured and 

recorded as whole-body (WB) dose in rem” 

(emphasis added). 

(3) TBD-6 does not discuss issues associated with the 

response of dosimeters to low-energy photons. 

There are statements to the effect that the 

dosimeter was similar in design to the Hanford 

dosimeter. The Hanford dosimeter applied a 

correction factor for exposure of plutonium 

facility workers to compensate for badge 

shortcomings. The ER indicates there are source 

term data available to bound low-energy photon 

dose.

The SEC proposed class definition will be reassessed in light of new 

information regarding potentially unmonitored workers. An external coworker 

model has been completed and is in stages of final revision.

(2) This statement is contradicted in Section 6.4, where it states, “...It is 

assumed that the dose recorded was the result of fast neutron exposure” 

(emphasis added).

The second statement is likely to be correct, since the common practice at 

DOE facilities was to assess NTA film for tracks produced by proton 

recoil. It is unlikely that NTA dosimeters were modified and calibrated 

for track analysis of thermal neutrons. In the absence of empirical data 

involving neutron spectra for reactors and Pu fuel storage facilities, the 

lack of dosimeter calibration methods, and the relative insensitivity of 

NTA film to neutrons with less than 500 keV (or as much as 1 MeV), 

there remains an undefined level of uncertainty for recorded neutron 

doses. 

NIOSH (from TBD issues matrix 4.6-2 and 4.6-3): 

While the above statement is correct it has very limited impact on DR other

than to make any result more claimant favorable. Neutron spectra 

measurements done in similar facilities have found doses resulting from 

neutrons < 100 keV to be, at most, less than 5% of the total neutron doses. (See 

ORAUT-TKBS-0003).

While we do not have neutron spectra for the Area IV facilities we do have 

spectral data for other similar facilities (Y-12, Hanford, SRS) and the correction 

factors given in the SSFL Site Profile are bounded by them. Neutron exposures 

are most likely associated with operations of the higher-energy D-T 

Accelerators and would be reasonably recorded by NTA film. The option to 

assign a neutron dose using the recorded photon dose for each worker and an 

appropriately selected neutron-to-photon dose ratio is also available. The issue 

is still being investigate with the on-going TBD review.

(3) No specific information on source term is provided. Furthermore, there is 

no consideration for dose from skin contamination incidents.
Santa Susana Issues Matrix 19 SC&A –September 2014 

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NIOSH response: 

The issues regarding the energy dependence of early film dosimeters have been 

resolved on various site profiles. This is not an SEC issue.

2014 Update: Open.

SSFL neutron-to-photon survey data were reviewed and a neutron/photon 

ratio approach developed. This was presented in a white paper sent to the 

work group in June 2010. Internal NIOSH issue resolution continues. 

Detailed guidance will be incorporated into the TBD once all issues have 

been resolved.
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References

42 CFR 83. Title 42, Part 83, of the Code of Federal Regulations. Procedures for Designating 

Classes of Employees as Members of the Special Exposure Cohort Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule, Federal Register/ Vol. 69, 

No. 104/Friday, May 28, 2004, p. 30764.

AI (Atomics International) 1959. SRE Fuel Element Damage, An Interim Report (NAA-SR4488). November 15, 1959.

AI (Atomics International) 1961. SRE Fuel Element Damage, Final Report (NAA-SR-4488 

(suppl). 1961.

Alexander, R.E., 1967a. Internal Letter from R.E. Alexander (Supervisor, Radiation Safety Unit, 

Atomics International) to M.E. Remley, Subject: Uranium Fire Incident A-0606: Radiation 

Safety Unit Weekly Newsletter for Week Ending February 4, 1967 - SSFL, February 9, 1967.

Alexander, R.E., 1967b. Internal Letter from R.E. Alexander (Supervisor, Radiation Safety Unit, 

Atomics International) to M.E. Remley, Subject: Uranium Fire Incident A-0605: Radiation 

Safety Unit Weekly Newsletter for Period Ending February 18, 1967 – SSFL, February 28, 1967.

Alexander, R.E., 1967c. Internal Letter from R.E. Alexander (Supervisor, Radiation Safety Unit, 

Atomics International) to M.E. Remley, Subject: Uranium Fire Incident A-0611: Radiation 

Safety Unit Weekly Newsletter for Week Ending March 11, 1967 – SSFL, March 24, 1967.

Alexander, R.E., 1967d. Internal Letter from R.E. Alexander (Supervisor, Radiation Safety Unit, 

Atomics International) to M.E. Remley, Subject: Uranium Fire Incident A-0615 and A-0616: 

Radiation Safety Unit Weekly Newsletter for Period Ending May 27, 1967 – SSFL, June 1, 

1967.

Badger, F.H., 1960. Radiological Safety Incident Report from F.H. Badger (Operational Health 

Physics, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0344: HQ 

0010, Room 115 - SSFL, December 5, 1960.

Badger, F.H., 1961. Radiological Safety Incident Report from F.H. Badger (Health and Safety 

Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0454: 

Cresta Grinder, Room 1059 – SSFL, May 2, 1961.

Begley, F.E., 1976. Incident Report from Begley, F.E. (Radiation and Nuclear Safety, Rockwell 

International) to R.J. Tuttle, Subject: Uranium Fire Incident A-0640: SNM Transfer Can Drop 

C/001 – SSFL, September 2, 1976.

Boeing 2003. Site Environmental Report for Calendar Year 2002, DOE Operations at the 

Boeing Company, Rocketdyne Propulsion & Power, The Boeing Company. September 2003.
Santa Susana Issues Matrix 21 SC&A – September 2014

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of 

this matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted.

Boeing 2004. Site Environmental Report for Calendar Year 2003, DOE Operations at the 

Boeing Company, Rocketdyne Propulsion & Power, The Boeing Company. September 2004.

Boeing 2005. Site Environmental Report for Calendar Year 2004, DOE Operations at the 

Boeing Company, Santa Susana Field Laboratory, The Boeing Company. September 2005.

Boeing 2006. Site Environmental Report for Calendar Year 2005, DOE Operations at the 

Boeing Company, Santa Susana Field Laboratory, The Boeing Company. September 2006.

Boice, J.D., S.S. Cohen, M.T. Mumma, E.D. Ellis, K.F. Eckerman, R.W. Leggett, B.B. Boecker, 

A.B. Brill, and B.E. Henderson, 2006a. Mortality among Radiation Workers at Rocketdyne 

(Atomics International), 1949–1999. SRDB Ref ID: 39396.

Boice, J.D., R.W. Leggett, E.D. Ellis, P.W. Wallace, M.T. Mumma, S.S. Cohen, A.B. Brill, B. 

Chadra, B.B. Boecker, R.C. Yoder, and K.F. Eckerman, 2006b. A Comprehensive Dose 

Reconstruction Methodology for Former Rocketdyne/Atomics International Radiation Workers. 

Health Physics, 90 (5): 409-430; May 2006; SRDB Ref ID: 37539. 

Curphey, J., 1983. Memorandum from J. Curphey (District Sanitary Engineer for the State of 

California, Department of Health Services, Sanitary Engineering Section) to T.J. Gannon 

(Rockwell International), Subject: Rockwell International Corporation, Rocketdyne Division, 

System No. 56-004. March 9, 1983.

Dempsey, G.D., 1989. Site Visit to Santa Susana Field Laboratory Operated by Rockwell/ 

Rocketdyne, U.S. Environmental Protection Agency. July 28, 1989.

DOE 1991. Tiger Team Assessment DOE/EH- 0175 – Energy Technology Engineering Center, 

U.S. Department of Energy, April 1991; OSA Ref ID: 103714.

DOE 1998. DOE Standard: The Department of Energy Laboratory Accreditation Program 

Administration, DOE-STD-1111-98; U.S. Department of Energy DOE); December 1998.

Federal Register, August 23, 2004 (Vol. 69, No. 162, pp. 51825-51831). 

Harrison, D.J., 1986. Internal Letter from D.J. Harris (Member, Technical Staff, Nuclear 

Operation, Rockwell International) to “Those Listed,” Subject: Uranium Fire Incident A-0165: 

Ignition Incident during Disassembly of Assembly #204, Cell 4 - SSFL, October 30, 1986.

Hart, 1962, Distribution of Fission Product Contamination in the SRE, NAA-SR-6890; R.S. 

Hart; March 1, 1962; SRDB Ref ID: 39770

Kellehar, R.G., 1966. Memorandum to R.E. Alexander, Subject: A Basis for Routine Urine 

Sampling of Workers Exposed to Plutonium-239. October 19, 1966.
Santa Susana Issues Matrix 22 SC&A – September 2014 

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of 

this matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted. 

Klostermann, J.P., 1961. Radiological Safety Incident Report from J.P. Klostermann 

(Operational Health Physics, Atomics International) to E.C. Hickey, Subject: Uranium Fire 

Incident A-0378: Building 009 – SSFL, July 13, 1961. 

Loba, M.L., 1959. Radiological Safety Incident Report from M.L. Loba (Operational Health 

Physics, Atomics International) to Health Physics Supervisor, Subject: Uranium Fire Incident A0422: Room 807 – SSFL, September 10, 1959. 

Loba, M.L., 1960. Radiological Safety Incident Report from M.L. Loba (Operational Health 

Physics, Atomics International) to R. Wilmes, Subject: Uranium Fire Incident A-0343: Pluto 

Area, Room 1244 – SSFL, December 1, 1960. 

Loba, M.L., 1961a. Radiological Safety Incident Report from M.L. Loba (Health and Safety 

Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0398: 

Room 1059 – SSFL, May 2, 1961. 

Loba, M.L., 1961b. Radiological Safety Incident Report from M.L. Loba (Operational Health 

Physics, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0503: Room 

1063 – SSFL, October 31, 1961. 

Loba, M.L., 1962. Radiological Safety Incident Report from M.L. Loba (Health and Safety 

Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0516: 

Room 1261 – SSFL, August 9, 1962. 

Loba, M.L., 1970. Internal Letter from M.L. Loba (Associate Health Physics, Operational 

Safety, North American Rockwell) to W.F. Heine, Subject: Uranium Fire Incident A-0636: 

Depleted Uranium Fire in Room 119-42, HQ-001 – SSFL, June 18, 1970. 

 

Lochbaum, D.A., 2006. An Assessment of Potential Pathways for Release of Gaseous 

Radiocativity Following Fuel Damage During Run 14 at the Sodium Reactor Experiment. 

October 5, 2006; SRDB Ref ID: 37247. 

Mooers, A.R., 1959a. Radiological Safety Incident Report from A.R. Mooers (Operational 

Health Physics, Atomics International) to Health Physics Supervisor, Subject: Uranium Fire 

Incident A-0528: Room 807 – SSFL, August 20, 1959. 

Mooers, A.R., 1959b. Radiological Safety Incident Report from A.R. Mooers (Operational 

Health Physics, Atomics International) to Health Physics Supervisor, Subject: Uranium Fire 

Incident A-0450: Room 901 – SSFL, August 31, 1959. 

Mooers, A.R., 1960. Radiological Safety Incident Report from A. R. Mooers (Atomics 

International) to Health Physics Supervisor, Subject: Uranium Fire Incident A-0235: HQ 1, 

Room 1063 – SSFL, June 22, 1960.
Santa Susana Issues Matrix 23 SC&A – September 2014

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of 

this matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted.

Mooers, A.R., 1961a. Radiological Safety Incident Report from A.R. Mooers (Health and Safety 

Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0453: 

HQ 1, Room 1059 – SSFL, March 20, 1961.

Mooers, A.R., 1961b. Radiological Safety Incident Report from A.R. Mooers (Health and Safety 

Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0353: 

SS Vault, Room 1142 – SSFL, May 8, 1961.

Mooers, A.R., 1961c. Radiological Safety Incident Report from A.R. Mooers (Operational 

Health Physics, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0455: 

Room 1059 – SSFL, July 24, 1961.

Moore, J.D., W.L. Fisher and P.A Rowe, 1962. Environmental Monitoring Semi/Annual Report 

January 1, 1962 to June 30, 1962. NAA-SR-7650, Atomics International, Canoga Park, 

California. November 30, 1962. 

NIOSH (National Institute for Occupational Safety and Health) 2002. External Dose 

Reconstruction Implementation Guideline, Rev. 1, OCAS-IG-001, Office of Compensation 

Analysis and Support, Cincinnati, Ohio.

NIOSH 2008. SEC Petition Evaluation Report, Petition SEC-00093: Santa Susana Field 

Laboratory (SSFL), February 6, 2008.

Oldfield, K.G., 1961. Radiological Safety Incident Report from K.G. Oldfield (Operational 

Health Physics, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0550: 

Building 4, Room 423-29 – SSFL, February 14, 1961.

ORAUT (Oak Ridge Associated Universities Team) 2006a. Technical Basis Document: Energy 

Technology Engineering Center – Site Description, ORAUT-TKBS-0038-2, Rev. 00. Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. February 2, 2006.

ORAUT (Oak Ridge Associated Universities Team) 2006b. Technical Basis Document: Energy 

Technology Engineering Center – Occupational Internal Dose, ORAUT-TKBS-0038-5, Rev. 00. 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. February 22, 2006.

ORAUT (Oak Ridge Associated Universities Team) 2006c. Technical Basis Document for

Atomics International – Occupational External Dosimetry, ORAUT-TKBS-0038-6, Rev. 01. 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. November 6, 2006.

ORAUT (Oak Ridge Associated Universities Team) 2007. Technical Basis Document: Area IV 

of the Santa Susana Field Laboratory, the Canoga Avenue Facility (Vanowen Building), the 

Downey Facility, and the De Soto Avenue Facility (sometimes referred to as Energy Technology 

Engineering Center [ETEC] or Atomics International) – Occupational Environmental Dose, 

ORAUT-TKBS-0038-4, Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

March 8, 2007.
Santa Susana Issues Matrix 24 SC&A – September 2014

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of 

this matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted.

Owens, D.E., 1978. Internal Letter from D.E. Owens (Radiation and Nuclear Safety, Rockwell 

International) to R.J. Tuttle, Subject: Uranium Fire Incident A-0065: Emergency ResponseUranium Fire at T028 – SSFL, March 28, 1978.

Rudkin, R.D., 1964a. Incident Report from R.D. Rudkin (Health and Safety, Atomics 

International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0434: Building 1, Room 1126 

– SSFL, January 20, 1964.

Rudkin, R.D., 1964b. Incident Report from R.D. Rudkin (Health and Safety, Atomics 

International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0407: Building 1, Room 1126 

– SSFL, February 20, 1964.

Rudkin, R.D., 1964c. Incident Report from R.D. Rudkin (Health and Safety, Atomics 

International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0436: HQ 1, Room 1131 and 

1114 – SSFL, March 12, 1964.

Rutherford, 2005, Sodium Reactor Experiment (SRE) Original Accident Release Data, 

memorandum to E. Crawford; Phil Rutherford; January 21, 2005; SRDB Ref ID: 19161 and 

19162

Santa Susana Field Laboratory SEC Petition. 2007. SEC Petition on SSFL to the Office of 

Compensation and Analysis, SEC-00093.

Special Exposure Cohort Petition 00093—Form B: June 22, 2007; OSA Ref ID: 103252.

Stephenson, R.M., 1961. Radiological Safety Incident Report from R.M. Stephenson (Health 

and Safety Department, Atomics International) to J.C. Lang, Subject: Uranium Fire Incident 

A-0357: Fed Area, Room 1026 – SSFL, November 27, 1961.

Stephenson, R.M., 1962. Radiological Safety Incident Report from R.M. Stephenson (Health 

and Safety Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident 

A-0355: FEPF, Room 1153 – SSFL, March 26, 1962.

Stephenson, R.M., 1963a. Radiological Safety Incident Report from R.M. Stephenson (Health 

and Safety Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident 

A-0541: Room 1059 – SSFL, March 11, 1963.

Stephenson, R.M., 1963b. Radiological Safety Incident Report from R.M. Stephenson (Health 

and Safety Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident 

A-0498: Room 1252, SNAP – SSFL, August 28, 1963.

Weber, R.K., 1963. Radiological Safety Incident Report from R.K. Weber (Health and Safety 

Department, Atomics International) to R.F. Wilmes, Subject: Uranium Fire Incident A-0360: 

Building 004, Room 424-68 – SSFL, December 20, 1963.

Winzer, C.E., 1980. Internal Letter from C.E. Winzer (Atomics International) to “Those Listed,” 

Subject: Drinking Water Supply—SSFL, August 14, 1980.
Santa Susana Issues Matrix 25 SC&A – September 2014

NOTICE: This September 2014 version of the issues matrix is cleared for public release. Note, however, that future versions of 

this matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted.

Winzer, C.E., 1981. Letter from C.E. Winzer (Atomics International) to Mr. John Curphey, 

District Sanitary Engineer for the State of California, Department of Health Services, Sanitary 

Engineering Section, 3704 State Street, Suite 212, Santa Barbara, California 93105, January 9, 

1981. 

Young, L.N., 1965. Incident Report from L.N. Young (Health and Safety, Atomics 

International) to R.M. Hill, Subject: Uranium Fire Incident A-0489: Building 022, AMP 

Evaporator – SSFL, May 18, 1965.

Young, W.A., 1960. Internal Letter from W.A. Young (Solid Waste Chemistry Unit, Atomics 

International) to R.H. Beight, Subject: Uranium Fire Incident A-0006: Explosion in Room 426-

13 – SSFL, July 27, 1960.